Case Digest (G.R. No. 108292)
Facts:
Republic of the Philippines (Presidential Commission on Good Government [PCGG]) v. Sandiganbayan, G.R. No. 108292; Republic of the Philippines v. Sandiganbayan, G.R. No. 108368; Montinola, et al. v. Sandiganbayan and Roberto S. Benedicto, G.R. Nos. 108548-49; Montinola, et al. v. Sandiganbayan and Roberto S. Benedicto, G.R. No. 108550, September 10, 1993, the Supreme Court En Banc, Melo, J., writing for the Court.
The consolidated petitions challenge the validity and the Sandiganbayan's approval of a global compromise agreement dated November 3, 1990 between Roberto S. Benedicto and the PCGG (then represented by Chairman David M. Castro). Petitioners sought annulment of the agreement and setting aside of the Sandiganbayan decision of October 2, 1992 that approved the settlement and rendered judgment pursuant to its terms. G.R. Nos. 108548-49 and 108550 were filed by eleven sugar planters and two milling corporations who additionally sought leave to intervene in Sandiganbayan Civil Cases No. 0024 and No. 0028.
The disputed compromise consolidated several matters (Sandiganbayan Civil Case No. 0009, Civil Case No. 00234, Civil Case No. 0034, the Phil-Asia case before the Tanodbayan, and PCGG I.S. No. 1) arising from complaints for reconveyance, reversion, accounting, restitution and damages against former President Ferdinand E. Marcos, members of his family, and alleged cronies including Benedicto. It was the third in a series of global settlements with Benedicto; prior agreements settled U.S. and Swiss proceedings in 1990, and temporary arrangements concerning Benedicto’s media businesses existed since 1986.
Under the November 3, 1990 compromise, Benedicto and affiliated corporations ceded listed properties (Annex A) and assigned rights in corporate assets (Annex B) to the Government; the PCGG agreed to lift sequestrations over assets listed in Annex C, extended broad immunity from criminal investigation or prosecution for acts prior to February 25, 1986, and undertook not to obstruct restoration or issuance of passports for Benedicto and his wife. The Government began implementing the agreement, taking custody and selling some ceded assets under privatization programs.
New PCGG leadership later challenged the agreement, alleging fraud, misrepresentation, contravention of law and public policy (notably Republic Act No. 3019) and arguing the PCGG lacked authority or had been misled; the PCGG sought renegotiation or rescission. The Sandiganbayan, after motions, oppositions (including from the Solicitor General), hearings, and a temporary restraining order in related proceedings, found no vitiation of consent, held the compromise not contrary to law/morals/public policy, and concluded the parties executed the agreement freely and voluntarily; it therefore approved ...(Pro-only)
Issues:
- Did the Sandiganbayan commit grave abuse of discretion in approving and enforcing the November 3, 1990 compromise agreement between the PCGG and Roberto S. Benedicto?
- May the Government (through the PCGG) repudiate or rescind a judicially approved compromise agreement after it has accepted and implemented its benefits, on grounds that the agreement is contrary to law, public policy, or tainted by fraud?
- Were the sugar planters and milling corporations entitled to intervene in the Sandiganbayan proceedings to challenge the approval of the compromise agre...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)